Home and Community Based Services Update #6 (posted 5/17/18)
Across Macomb County our Residential and Non-Residential
Providers are thoughtfully working on Corrective Action Plans (CAPs) to best remediate
areas of concern discovered in the annual federal mandated Home and Community
Based Services (HCBS) surveys. These surveys are the primary tool that the
Michigan Department of Health and Human Services MDHHS used to construct our
Michigan State Transition Plan. (STP)
When these plans are submitted to the Center for Medicare/Medicaid Services,
they will decide whether our state is in substantial alliance and compliance with
the HCBS Final Rule.
The HCBS Final Rule is a Federal regulatory design that aims
to improve the care and daily living experience of our Intellectually
Developmentally Delayed (IDD) and some of our Severe Mentally Ill (SMI)
consumers. The HCBS Final Rule specifically targets those IDD/SMI consumers
that live in a dependent setting like a Licensed Specialized Adult Foster Home (AFC)
and receive specialized clinical services like Community Living Services (CLS),
Skill Building, and Vocational Services.
The HCBS Final Rule mandates consumers living in a dependent
setting receive their Medicaid services integrated into our general community,
in a non-isolating manner, and not isolated from the greater community. It
requires providers to respect individual choice, and support consumer self-determination.
The HCBS Final Rule and State Transition Plans across the
county bring an element of “high level” or big picture trends across these
treatment services. It may have the effect of assessing the delivery of care,
moving from a reporting style measurement, to more direct focused elements on
outcome based measurement. This is a trend across health care in general.
Our MCCMH system values all our provider partners. Together
we are greater than the sum of our parts. Our joint fields recognize that
examining our efficiency and efficacy by prudent measurement are part of our
fabric of service today.
Home and Community
Based Services Update #5 (posted 3/19/18)
Macomb
County Community Mental Health is now in the process of completing the B3
Wavier Survey. For our people served, their family and friends, plus our
Provider Network, the time taken to address this meaningful task is
appreciated.
In
February, letters from Michigan Health and Human Services (MDHHS) outlining
areas of opportunity and requests for changes were distributed to Residential
and Non-Residential Providers involved in the HCBS Part I and II Surveys done
in the fall of 2017. There are Corrective Action Plans (CAPs) for both types of
Providers to come into compliance with the HCBS Final Rule by March of 2019.
Running concurrently is the MDHHS effort at Heightened Scrutiny (HS) Resolution
directed by MDHHS. There is a MDHHS Frequently Asked Question link at the end
of this update for reference. s an aide to general understanding, and l background,
Please see State of Michigan Medicaid Provider Manual
Policy Bulletin MSA-17-31 is below: (Link available below)
In
order to comply with the federal HCBS Final Rule, (…) providers must:
• Ensure individual
rights of privacy, dignity and respect, and freedom from coercion and
restraint
• Enhance independence
• Enhance independence
in making life choices
• Enable choice
regarding services and who provides them
• Ensure that the
setting is integrated in and supports full access to the greater
community
The HCBS Final Rule is
focused upon consumer choice. We promote our consumers to engage in meaningful
choice and active participation in MCCMH services. We want to help build consumer
self-direction and meaningful participation in all aspects of our shared
community. We work with an ardent desire
to have our Michigan Constitutionally mandated CMH IDD service population,
experience community inclusion to receive services in a non-isolative manner
within our community while living in a non-institutional setting.
http://www.michigan.gov/documents/mdhhs/MDHHS_FAQ._R_6.26.17docx_576922_7.pdf
http://www.michigan.gov/documents/mdhhs/MSA_17-31_599587_7_600816_7.pdf
FAQ - Heightened Scrutiny, shared by Michigan Department of Health and Human Services (posted 1/17/18)
Home and Community
Based Update #4
Dec. 20, 2017 -- Part of the State Transition Plan (STP) for
the Home and Community Based Service (HCBS) Final Rule is examining and
correcting settings that may not meet these new rules and guidelines yet. The
HCBS survey process helped the Michigan Department of Health and Human Services
to identify Providers or settings, in all 10 Regions across the state that are
not currently compliant with HCBS Final Rule guidelines. The State Transition
Plan includes allowing time and support to Providers that choose to continue
providing services, to come into compliance.
MCCMH values our Provider Network. We plan to partner with
Non-Compliant Providers to make changes and reach HCBS Final Rule compliance.
All 10 Regional PIHPs are using a Corrective Action Plan (CAP) process as a tool
to achieve this goal.
The Macomb Notification letters will be out to Providers by
February 12. They will be delivered with the CAPs material, and the entire
packet will come through the secure MCCMH Business Management Portal. This
method is password secure. It is the same process used to deliver annual
contracts and important business documents.
Most of the Non-compliant issues will involve the seven
mandated requirements of the HCBS Final Rule. (See below) Those Providers that
provide service in other Regions and counties may already be familiar with the
CAP process. It is anticipated that corrective strategies that were found
acceptable in other PIHP/CMHSP settings will also be viable, albeit with small
“tweaks” in others. Please remember the CAP process is multi-layered, i.e.
MDHHS reviews and gives final approval to all CAPs state wide, which will in
turn are then reviewed and given final approval by CMS.
• Individual
has a lease or other legally enforceable agreement providing similar
protection;
• Setting is
selected by the individual from among setting options;
• Individual
has privacy in his/her unit including lockable doors;
• Individual
has a choice of roommates (if applicable) and freedom to furnish or decorate
the unit;
• Individual
controls his/her own schedule, including access to food at any time;
• Individual
can have visitors at any time; and
• Setting is
physically accessible.
Providers can please see the Michigan Department of Health
and Human Services (MDHHS) HCBS web page http://www.michigan.gov/mdhhs/0,5885,7-339-71547_2943-334724--,00.html or outreach the HSW Administrator for Macomb
at email ken.schleicher@mccmh.net
Home
and Community Based Services Update Grapevine #3
Dec.
11, 2017 -- In October the notification letters for residential and
non-residential providers found to be in HCBS Heightened Scrutiny were sent
out. It is important to remember HCBS Heightened Scrutiny is reversible. The
“scrutiny” refers to the Provider’s service delivery, and not the consumer’s
medically needed treatment. The entire HCBS Final Rule is overseen by the
Federal Center for Medicare and Medicaid Service (CMS) in our nation’s capital.
Providers
were tagged for this status based upon consumer and/or provider answers to HCBS
survey questions, as developed by Michigan Department of Health and Human
Services (DMHHS) and facilitated by Development Disability Institute of Wayne
State University (DDI/WSU).
What
does this mean? The Heightened Scrutiny category means that initial MDHHS State
Transition Plan surveys identified the provider as possibly having qualities
that may be institutional like, or having the effect of isolating the consumer,
or of lacking consumer integration into the greater community. Improving the
daily life quality for consumers in these three areas is the milestone aim of
the HCBS Final Rule.
The
first step locally for both Providers and individuals receiving services in a
setting found to be in Heightened Scrutiny is official notification by letter.
After that an official decision of intent or choice by both consumer and
provider is required.
The
Heightened Scrutiny category can only be remediated by the Michigan Department
of Health and Human Services. Consumer choice is preserved by the
treatment system. This process is not abrupt. The resolution will unfold along
lines designed to facilitate zero interruption in consumer care.
Resources
are available to help the providers. MCCMH is dedicated to improving our
treatment network and the services that we provide to our consumers and
families.
See
the following links for more detailed information. You can also contact the
MCCMH HSW Administrator, HCBS-B3@mccmh.net
or work cell: 586 602 3010.
Home
and Community Based Services Update Grapevine #2
Our
MCCMH Pre-Paid Inpatient Healthcare Plan (PIHP) is approaching the end of
another HSW Waiver survey period. This portion of the survey process focused on
consumers receiving what used to be commonly called the Michigan HSW B3 Waiver
plan. Both the former HCBS C Waiver and the HSW B3 Waiver now are referred to
as 1115 Waivers.
We
have been surveying consumers, facilitated by Case managers, and Providers of
Community Living services, Skill Building services, Supported Employment
services, and Licensed Adult Foster Care Home Providers as directed by the
Michigan Department of Health and Human Services. Our purpose is to fulfill the
State Transition Plan on Compliance with the federally mandated Home and
Community Based Service (HCBS) Final Rule first rolled out in 2014.
We
have already commented on the overarching philosophy of promoting inclusion,
community integration and avoidance of institutional-like care for our consumer
populations. A short summation statement of the HCBS Final Rule is reviewed
here as General Philosophical Requirements:
· Ensure individual
rights of privacy, dignity and respect, and freedom from coercion and restraint
· Enhance
independence
· Enhance
independence in making life choices
· Enable choice
regarding services and who provides them
·
Ensure that the setting is integrated in and supports full access to the
greater community.
There
are also seven concrete objectives which are designed to assure and promote
respect, dignity, and personal choice. Here is a specific list of the HSW Final
Rule Components for Compliance:
·
Setting is selected by the individual from among setting options;
·
Individual has a lease or other legally enforceable agreement providing
similar protection
·
Individual has privacy in his/her unit including lockable doors
·
Individual has a choice of roommates (if applicable) and freedom to
furnish or decorate the unit
·
Individual controls his/her own schedule, including access to food at
any time
·
Individual can have visitors at any time
·
Setting is physically accessible.
Over the coming year the
supporting policies and procedures will be woven into our ongoing Strategic
Plan to assure the PIHP network successfully meets these Federal Mandated
standards.
Home
and Community Based Services Update Grapevine #1
Oct.
11, 2017 -- Our county, as represented by MCCMH, Prepaid Inpatient Health Plan,
expects to receive notification this month of initial results and findings from
last year’s HCBS Participant and Provider survey initiated by Michigan
Department of Health and Human Services. This effort is commonly called the
HCBS Survey, Part I and II. The survey sent questionnaires to measure both
consumer and service providers’ compliance with the federally mandated HCBS
Final Rule. Our first survey was completed last December. When this effort
started in 2014, we were given a five year time period to come into compliance,
2019. This year the Federal government has given all states another three
years.
Three
types of outcomes are expected from the HCBS Final Rule survey process; compliance,
non-compliance and Heightened Scrutiny status. If a provider agency is judged
as compliant, no immediate action is necessary.
For
providers found out of compliance, there will be a period of correction
opportunity encouraged. This should allow most providers to come into HCBS
Final Rule compliance. It is also possible that a small percentage of provider
agencies may fall into the third, Heightened Scrutiny (HS) status.
This
last category means that joint work between the provider agency and Michigan
Department of Health and Human Services will need to occur in order for the
provider to remain in good standing with the Department. This step must be
accomplished in order for Macomb, our PIHP, to continue to contract for
services using Medicaid funds.
The
federally mandated compliance with HCBS Final Rule promotes equal access and
participation opportunity to the larger community. There are broad philosophic
goals of equality, dignity of person, and respect.
These
high level requirements and rules are identified. Each community across the
nation is challenged to demonstrate adherence to the HCBS Final Rule when
providing specialized Behavioral Healthcare services to our mission target
groups; seriously mentally ill, (SMI) intellectually developmentally delayed,
(IDD) and seriously emotionally disturbed children and adolescents. (SED)
All
providers must demonstrate compliance in their business settings in these three
areas. The provider agency must be non-Institutional like in environment
and practice. The provider agency should not isolate consumers by practice or
effect. HCCBS recipients should enjoy the same community access as the average
citizen. Lastly the provider agency and business setting should promote
inclusion and equal access to meaningfully participate in the larger community.